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Work ing together for a safer L ondo n

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EQUALITY IMPACT ASSESSMENT

Form 6119A

The Equality Impact Assessment Standard Operating Procedure/Guidance must be usedwhen completing this form :

2

Protective Marking : Not Protectively Marked Publication Yes

Title : Met Detention EIA

Branch / OCU : Met Detention

Date Created 11/06/14 Rev i ew Date: constant Vers i on : 8

Author:

Person completing EIA :

Signed : 3=1

Person supervising EIA :

Signed : DCI A. Chambers

Quality Assurance approval :

Name: S. Fores

Date: 11 /06/1 4

Date: 28/08/1 4

Unit Portfolio Planning Date 11/06/1 4

Decision Making

Decision Maker :

Name: Annette Wightman - Met Detention Rank or Grade: Supt

What is the decision?

Reject the proposal Yes ❑

Implement the proposal Yes

Produce an alternate proposal (if so, a new impact assessment Yes❑

must be completed )

SMT / (B)OCU/Management Board endorsing decision

No

No ❑

No

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Name : Rank or Grade :

1 . Aims and Purpose of Proposal - see step 1 of the guidance

This EIA seeks to examine the diversity implications and impact on protected characteristics (as defined bythe Equality Act 2010) , presented by the creation of Met Detention and , makes appropriaterecommendations for activity to mitigate any adverse impact . The EIA is undertaken to comply with thegeneral duty (section 149) of the Equality Act 2010 that states that organisations should demonstrate dueregard to the requirements of s . 149 Equality Act 2010 to :

(a) eliminate discrimination , harassment, victimisation and any other conduct that is prohibited by o runder this Act ;

(b) advance equality of opportunity between persons who share a relevant protected characteristic an dthose who do not share it ;

(c) Foster good relations between persons who share a relevant characteristic and persons who do no tshare it .

The Metropolitan Police Se rv ice (MPS) recognises that specific protected characteristics aredisproportionately vulnerable whilst in custody . The EIA will identify these vulnerabilities and outline activityto minimise them . In doing so it will be cognisant of Lord Adebowale 's report into the handling of mental illhealth incidents by the MPS - as they relate to Met Detention .

Current state i .e . pre - Met Detention

The strategic direction for custody is set by the MD Senior Leadership Team (SLT) . The SLT are supportedby teams who set policies and professional practice for Permanent Custody Teams (PCT) .

Service delive ry is through the PCT that are based at each of the thirty 24/7 suites . Each PCT is comprisedof a Custody Manager (CM) , Custody Officers (CO) and Designated Detention Officers (DDOs) . Boroughswith more than one 24/7 suite have been allocated one CM . Their posts are contained within boroughestablishments and report to a Borough SLT custody lead . This leads to an inconsistent delive ry of custodyservices as Borough SLTs have different interpretations on how custody services should be delivered andadapt the direction , policies and professional practice set by Met Detention .

The LPM has delivered PCTs that work to local demand profiles however , their staffing models have notbeen designed to be fully resilient . Lack of resilience is particularly acute for times when demand profilespredict lower demand as staffing levels at these times are lowest affecting the ability to grant leave ormanage the operational impact of short-notice absence . Resilience is also problematic at weekends whenthe most Annual Leave is granted by boroughs . Consequently boroughs have to either backfill from otherbusiness areas or , choose to operate with PCT numbers below those needed to effectively manage demand .

The Local Policing Model (LPM) has increased the number of Inspectors pe rforming a custody role throughthe introduction of a new role - the Custody Support Inspector (CSI) . CM/CSIs work together in clusterteams to improve the levels of leadership in custody .

With the exception of PFI initiatives at Sutton , Lewisham and Bromley (providing buildings and accreditedDDOs) , there is no current outsourcing of custody se rv ices in the MPS .

Met Detention is responsible for the delive ry of Forensic Healthcare Services via an in-house multidisciplina ry service of Forensic Medical Examiners (FMEs) , Custody Nurse Practitioners (GNPs) andCustody Nurse Practitioner Area Managers .

The estate is managed via a tri-partite arrangement of Met Detention , Property Services and TerritorialPolicing .

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Future State : Met Detention

On October 1st 2013 , Management Board approved the development and introduction of a central detentioncommand as part of Met CJ - Met Detention . This centralised model will see the existing Met Detention SLTtake line management responsibility for PCTs and for the delive ry of custody services .

Met Detention will :

• Ensure that custody services are consistently delivered reflecting legislation , policy and professionalpractice enabling strategic direction to meet tactical delive ry ,

• Undertake the NHS Commissioning process ,

• Develop and implement a balanced approach to service delive ry that takes into account the differingneeds of all custody users - particularly those who fall within a protected characteristic and/or arevulnerable , and

• To support its balanced approach to service delive ry MD will improve its levels of self-sufficiency andcapacity via an uplift of 14 CSI posts , the introduction of corporate 11 and 12 hour shift patterns ,minimum staffing levels and the `flexing ' of staff between suites to meet demand .

The diagram below outlines the fully implemented Met Detention Operational Command Unit (OCU ) that willbe implemented in Janua ry 2015 .

Chief SuptOCU Commander

Superintendent- Operational Delivery- Management and devel opment of detentioninfrastructure- OCU Professionalism Champion- Line management of Professional Standards Unit- Line management of Custody Infrastructure Team- Line management of geographical C/Insp s

Custody Infrastructure TeamEfficient and effective use of custodyinfrastructure, IT and staffing levels;Continuous Improvement and NSPIS

support

Ch Insp

- Critical incidents- Implement balancedperformance model

- Development of customerrelationships

Ch Insp

- Critical incidents- Implement balancedperformance model


Ch Insp

- Critical incidents- Implement balancedperfocmmce model


15 a Insp64 a PS

124 z DDOGreenwich

BexleyBromley

IRW16h8mSouthwark

15 a Insp66 a PS

121 z DDOLambeth

W8Rd6W0[t lSutton

Croydon

15 a Insp7 0 aPS

1 08 z DDOWestminster

KensingtonIslingtonCamden

Superintendent- Operational delivery- Business Change- Development & implementation of alternative FHSprovision- Line management of Business Improvement Team- Line management of Forensic Health Care Tea m- Line management of geographical C/Insp s

Business Improvement TeamBalanced Service Delivery, Policy and

Professional Practice, SME advice, externalliaison, Inspection and Review

Ch Insp



Ch Insp



14 a Insp53aPS

97 z DDOHeathrow

HarrowBrent

BarnetHillngdon

14 a Insp61 x PS

102 z DDOEnfield

HaringeyHackney

Tower Hamlets

Forensic Health Care TeamIx Medical D i rect o rIx Nursing D i rect orIx Chief Inspector

2 a Ins pectors, Ix PC139 z Nurses

8 x Nurse Managers7 z Band D4i Band E

Ch Insp



Ch Insp



15 a Insp59aPS

12 7 z DD0Waltham Forest

Newh am

BarkingRedbridgeHavering

14 a Insp55 a PS

10 1 z DDOKingston

Hounslo wE aling

Hammersmith

Following the conclusion of the NHS Commissioning process , a decision will be made as to the future of theForensic Health Care team .

In addition , Met Detention is developing the provision of a Professionalism Unit and SLT support which willsupport the OCU .

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The Area Chief Inspectors (ACI) will take the lead in identifying and ensuring effective operational responsesto diversity issues within their suites .

2 . Examinat ion of Available Information - see step 2 of the gu idance

The information which he l p inform this EIA inc ludes:

Service Delivery

• A review of cell occupancy data and custody throughputs ,• Demand led shift pattern options produced by shift pattern analysts ,• Completed Borough Change Implementation Assessments ,• Performance information in relation to custody and investigative processes ,• Implementation interdependencies such as impact on partner agencies (Drug Intervention ,

Appropriate Adult provision for Adults , Mental Health provision , etc) ,• Implementation interdependencies with other MPS Change Projects , and• Impact of the MPS Estate Strateg y

The following information has also been taken into account however further examination of thedata is required and will be on going :

• Workforce monitoring identifying the personal characteristics of the current workforce withinBoroughs ,

• User Satisfaction Surveys ,• Complaints and comments

Information and direction received through consultation - see section 5 .

Characteristics of Custody Staff - December 201 3

The personal characteristics of members of PCTs and CSIs were captured in a base liningexercise to give a profile of the protected characteristics of Custody staff . Totals do not always addup to the same amount as some staff declined to answer certain questions .

Met Detention has gathered the data on protected characteristics that NSPIS allows . There is noability to search for gender reassignment , marriage and civil partnerships , pregnancy and maternityor sexual orientation .

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Any other Asian backgroundAny other Black backgroundAny other group not specified

Bangladesh iBlack - AfricanBlack - British

Black - Caribbea nChinese

Greek & Greek CypriotIndia n

Mi x ed - Any other mi x ed backgroundMi x ed - White & Asia n

Mi x ed - White & Black AfricanMi x ed - White & Black Caribbean

Not state d

T u rkish & Turkish CWhit e - BritishWh ite - IrishW h ite - Othe r

Un i

DDO <20 20-24 25-29 30-34 35-39 40-44 45-49 50-54 55-59 60 +M 414 5 79 99 52 26 44 40 34 25 5F 288 2 57 67 39 34 ~8 19 ~0 7 3

SGT <20 20-24 25 -29 30-34 35-39 40-44 45-49 50-54 55 - 59 60 +M 341 0 0 1 22 53 82 108 62 6 2F 73 0 0 0 12 1 7 1 4 25 3 0 0

INSP <20 20-24 25 -29 30-34 35-39 40-44 45-49 50-54 55 - 59 60 +M 66 0 0 0 0 1 8 26 14 4 0F 5 0 0 0 0 0 1 3 ~ 0 0

27

55

7

Characteristics of MPS Detainees - December 201 3

NSPIS again present data problems Met Detention has gathered the data on protected with noopportunity to search on disability , gender reassignment, pregnancy and maternity race , religionand belief or sexual orientation .

The data for Mental Health is likely to have inaccuracies . During the initial Risk Assessmentdetainees are asked whether they suffer from Mental Health conditions . It is the answer to thisquestion that generates the NSPIS data . Under reporting during the risk assessment may be anissue . Moreover , if it becomes apparent following the initial Risk Assessment that a detainee issuffering from a Mental Health condition , this cannot be collected for statistical purposes . This canbe a common occurrence when a detainee initially presents as being affected by alcohol and/orsubstance misuse and a Mental Health condition subsequently becomes apparent when the impactof the alcohol etc reduces .

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8651045-312726391310

1710

176

861

1843

138

Fema le 367Male 820

<20 720-24 13625-29 16730-34 12 535-39 13240-44 18145-49 22350-5d 15 455-59 4260+ 10

Fu ll Time 1 15 9c d . 5 6

0 . 5-0 .7 1 1X 0.7 22

Disab led 9

A n ostic 5Ath e ist 5Baptist 5

Christian 69Christian Orthodox 2

Church of ScotlandChurch of WalesGreek Orthodo x

HinduHumanist

Isla mJehovahs Witness

JewishMethodist

7

3

6

35

ProtestantRoman Catholi c

SalvationistSikh

Spiritualist

todActsBarking

ariasvwChiak_

EdmontonForest Gate

Hammersmith

HarrowHeathrowHolborn

Hou nslawIlford

Islin onKentish Town

KingstonLewisham

NomPaddin9tc

pre 'JItCrI

Stole

WembNest Dra onWood Green

Age of detainee

Gender MH 39 40-49 5U - 59 >6030

0 26% 15% 6ol0 2%M F Problems <~1o8 19

-37 io29

- ~l0 10/037% 13% 12% 12% 24% 0 4%

B70/to 13% 14% 17°~l0 40% 24% 1 2% 40l0 1°l0 B8°lo 12% 15% ~6~1° 42 ~70 21% 15% 5°l02%

84% 16°l0 18% 17% ~o~ 23°l0 16% 7% 2%

86% 14% 17% 15% ~o0 21% 16% 6°l0 20l0

83% 17% 21% 17% 350/0 25% 14% 6°!0 2%

0 0 13% 910 4 /0 0 0 7% 3%84 16/0 /0 1

PA51, 14% 18% 12% 1.11 of 73% 15% 6°!0 2%

r% 13% 16%

io 15% 17%

Ei% 14% 14%

7% 13% 13%

4% 16% 15%i6% 14% 13%37% 13°!0 10%

36% 14°l0 180l0

85% 15°!0 15%

86% 14°!0 13%

86% 14°!0 18%

gg% 12°!0 17%8~% 14°l0 19°l0

84% 16°!0 19%865% 14°l0 13°l0

86% 14°l0 15°l0

840 16°l0 17°l086% 140l0 13°l0

16% 20%84°l085% 15010 17%

87°l0 131/6 14718614% 19°/°%0$3°l0 17% 18

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page 6 of 18 44

1%

1%

1

Self Defined Ethnicity

Acton 114%14%10% 18%19% 110%14%12% 11%11% 12%12% 121%14%117%

Bethnal Green 11% I 1% 132%1 3% 15% 1 8%1 3% 1 3% 1 1% 0% 12% 1 2% 125%1 1% 110%

Brixton

Cha ring CrossChiswickCohn dale

EdmontonEnfield

Forest GateHammersmith

HarrowHeathrowHol bom

HounslowIlford

IslingtonKentish Tow n

Notting HillPaddingtorPlumsteadRomford

Shored itch) Ce Newin g

Sutton

1% 1 1% 1 1% 12%119%113%112%13% 11%1 0% 13%1 4% 121%I 2%113%

2% 2%12%15%15%19%16%11%11%10%12%111%122%12%125%10% 4% 1% 18%15% 17%14%12% 11%11% 12%12% 36% 2% 15%3% 2% 1% 6% 5% 10% 4% 2% 1% 0% 2% 4% 33% 3% 21 %

1% 1 1% 1 1% 13%110%113%1 7%12% 11%1 0% 12%1 4% 129%I 2%121 %

5% 1 8% 1 9% 15% 18% 1 16% I 6% 1 2% 1 1% 0% 12% 1 2% 118%1 1% 116%

8% 13%11% 113%17% 110%14%12% 11%11% 12%13% 126%14%113%

1% 2% 5% 3% 4% 10% 4% 2% 2% 1% 2% 3% 32% 4% 17%

11%

1100%/00

1% 7% 4% 8% 3% 2% 1% 1% 1% 2% 33% 2% 18%

9% 4% 6% 7% 9% 3% 2% 1% 1% 1% 3% 24% 1% 17%

1% 2% 2% 9% 9% 6% 4% 1% 1% 2% 3% 36% 4% 13%

2% 12%11% 15%13% 15%12%12% 11%11% 11%12% 154%12%112%

3% 1 8% 1 3% 15% 18% 1 10% I 7% 1 2% 1 1% 1 0% 12% 1 3% 121%I 1% 122%

1% 1 1% I 1% 14%18% 19%14%14% 11%11% 13%18% 129%12%115 %

1% 1 1% 1 1% 13%15% 115%18%12% 11%10% 12%12% 145%12%19 %

2% 11%17% 13%110%111%111%13% 11%10% 12%15% 123%13%115 %

2% 11%11% 14%15% 16%13%13% 11%10% 12%12% 155%12% 110%

Walworth 1% 1%11% 2%111%119% 8% 3% 1%10%12% 4% 28% 2% 11%Wandsworth 2% 3% 1% 4% 11% 8% 7% 4% 1% 0% 2% 3% 31% 2% 17%

Wembley 6% 3% 1% 7% 14% 14% 6% 2% 1% 1% 2% 3% 13% 4% 17%West Drayton 14% 3% 1% 4% 4% 10% 2% 1% 1% 1% 1% 2% 39% 3% 14%Wood Green 1% 1% 0% 1% 12% 14 % 5% 3% 0% 0% 1 % 2% 19% 5% 24%

Al As ian - Indian M2 Mixed - White and Black Af ri canA2 As ian - Pakistani M3 Mixed - White and As ianA3 As ian - Bangladeshi M9 Mixed - OtherA9 As ian - Other 01 Other - Chinese131 Black - Caribbean 09 Other - Any O ther E thnic G roupB2 Black - African W1 Whi te - Britis hB9 Black - Other W2 Whi te - IrishM1 Mixed - Whi te and Black Af rican W9 Whi te - Any Other Whi t e Background

Again , Met Detention has gathered all the information that NSPIS provides for detainee 's . There isno ability to search for

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The Diversity and Citizen Focus Directorate (DCFD) have assessed the suitability of 21 suites tosupport disabled and Muslim detainees , and Transgender detainees/staff . The findings were :

L~_l

Inspection Masterli s t . xl s (62 . . .

Development of future Protected Characteristic informatio n

Met Detention recognises the need to develop more sophisticated data regarding a fuller rangeprotected characteristics for both its workforce and for detainees . This is necessa ry to allow agreater understanding of issues such as :

• The potential impact of tactics such as PCR (street charging of cannabis) . A potentialimpact is that non-English speakers would be less likely to be offerd this and more likely tobe taken into custody , or

The increasing recruitment of Police Officers from DDOs may result in changes to the protectedcharacteristic profile of DDOs . Met Detention also recognises the need to develop faster timeinformation to understand and manage real-time and on-going risk connected to vulnerability via aMet Detention Grip and Pace process . For example , an understanding of the number of juvenilesarrested and detained daily together with the number of successful s38 PACE applications -transfer of juveniles to alternative local authority accommodation when bail is refused .

3 . Screening Process for relevance to Diversity and Equality issues - see step 3 ofguidance

Does this proposal have any relevance to :

a) Age Yes No ❑

b) Disability Yes No ❑

c) Gender Yes No ❑

d) Gender Reassignment Yes No ❑

e) Marriage and Civil Partnership(employment only) Yes

❑ No

f) Pregnancy and Maternity Yes No ❑

g) Race Yes No ❑

h) Religion or Belief Yes No ❑

i) Sexual Orientation Yes No ❑

j) Other Issues Yes No ❑

4 . From the answers supplied , you must decide if the proposal impacts upondiversity or equality issues . If yes , a full impact assessment is required .

Full Impact Assessment Required? Yes M No ❑

5 . Consultation / Involvement - see step 5 of the guidance

Who was consulted?

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1 s` consultationS .A . M . U . R .A . I . ;The Federation Sgts Branch Board , Inspectors Branch Board & Supt association .DoRTP - Met Detention TeamTP - Met Detention SLTTP - Met Detention Business as usual teamAll current custody inspectorsMet ProsecutionsDigital PolicingDCFDHQ Directorate of Media & CommunicationMet Change tea mMET-TUS SECRETARIATTP Criminal JusticeTPHQ ACPODoR (FinanceServ)TP - C&SMet Detention project board critical readersHQ Property Se rv ices Directorate

2"a consultationAssociation for Muslim Police (AMP) -4Jewish Police Association (JPA) 5Gay Police Association (GPA) -Black Police Association (BPA) -

Date and method of consultatio n

The EIA has been sent twice by e-mail to a wide range of stakeholders requesting feedback - asper the above schedule .

Met Detention Area Chief Inspectors have consulted locally to identify access issues to suitesaffecting disabled users .

DCI Chambers met with CS Bourlet (who is attached to the NHS undertaking Commissioning work)to discuss vulnerability resulting from Mental Health and Learning Difficulties .

On 11/9/14 the EIA was authorised by the OCU commander to be used for internal use and toproceed to external consultation .

Where are the consultation records stored ?

Met Detention project team email folders .

Give a brief summa ry of the results of the consultation /involvement? How have theseaffected the proposal?E-mail consultation resulted in feedback from 4 stakeholders . This is reflected in the EIA .

Access issues are being considered by the Met Detention project team and Property ServicesDirectorate .

The Disability section of the EIA reflects the discussion with DCS Bourlet .

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6 . Full Impact Assessment - see step 6 of the guidanc eExplain the potential impact (whether intended or unintended, positive or negative) ofthe proposal on individuals or groups on account of:

Age

Potential Workforce Impact s

If the age and length of service data indicates high percentages of officers approaching 30 yearsservice , consideration needs to be given to the potential risk of future implementation of A19(current legal and HR advice is that this is unlikely , but is included for completeness and todemonstrate consideration of the issue) and the potential loss of workforce members and skillsmix . Retirement arrangements and provision are in the process of being revised taking account ofrecent changes in legislation under the Equality Act 2010 abolishing the statuto ry retirement age of65 . This may lead to a greater age mix of employees within custody .

Shift working (particularly nights) can have a damaging affect on health and performance and mayincrease risk when travelling to or from work . It may impact on those with caring responsibilities -both positively and negatively .

All age ranges maybe affected by shifts although older staff maybe more adversely affected . Agewas a specific concern for the Inspectors Branch board as their members tend to be older and 11hour shifts may affect them more .

Mitigation

Further analysis to identify whether there is a potential risk to numbers and the skills/age mix of ourworkforce .

Met Detention has put in place safety control measures to assist and reassure staff . These include :

1) The development of shift patterns whereby a number of posts in each role will not have to work11/12 hour shifts or night duties . These shifts may be of particular use for Inspectors andSergeants due to the relative ages of the staff in these positions . They are however , also availablefor DDOs as well .

Inspectors - 8 will not need to work 11 hour shifts or ND , a further 45 will not need to work ND(45% )Sergeants - all will need to work 12 hour shifts , 44 will not need to work ND (10% )DDOs - 36 will not need to work 12 hour shifts or ND , an additional 4 will not need to work ND (5% )

2) Met Detention Area Chief Inspectors are working with boroughs to review all applications forFlexible Working Patterns (FWP) (including job sharing) in advance of go-live . These applicationswill be considered at a Met Detention FWP panel prior to go-live . The panel will look across allsuites to see if an application that can 't be supported in one suite can be supported in others . Workis under way with Human Resources to improve the current process for recording FWP to allowmore effective identification of job sharing opportunities across suites .

Possible External Impacts

Met Detention has a responsibility for cooperating with arrangements to improve the well-being ofjuveniles with regards to their physical and mental health and , to protect them from harm .

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• After an interview or other custody related interaction , the custody officer should explicitlyask if any safety or welfare issues were raised regarding the juvenile ,

• If neither the arresting or investigating officer are on duty when it becomes apparent that aPre-Assessment Checklist (PAC) is required for a juvenile , the custody officer must directanother officer to complete the PAC and communicate this to the appropriate agency ,

• The custody officer must provide Appropriate Adults (AA) with key information contained inthe juvenile ' s detention log and risk assessment ,

• When juveniles are released from custody suites which are a significant distance away fromwhere they were arrested or , where the custody suite is situated away from local transportlinks , this will be managed by the Custody Officer as part of their Pre Release RiskAssessment , and

• If bail is refused for a juvenile then attempts must be made to obtain alternative LocalAuthority (LA) accommodation unless it is impracticable to do so .

Boroughs have established individual arrangements with their LA to provide AA services . This hasled to inconsistent service delive ry .

In the future there maybe further reductions in the number of 24/7 custody suites leading tojuvenile detainees being taken to suites not on their LA area .

Mitigation

Met Detention will develop information that can be used to ensure that its SLT can effectivelyreview compliance with activity that will ensure the well being of juvenile detainees . ProfessionalDevelopment Days (PDD) will be used to reinforce these requirements .

Met Detention is reviewing the provision of AA support for juveniles to identify gaps in the provisionof this se rv ice .

Met Detention will ensure that consultation is undertaken with LA to minimise the impact of anyfuture estate change on the provision of AA se rv ices .

Disability

Potential Workforce Impact s

There is a historical reluctance for members of staff to self-declare as disabled on Met HR .

Certain disabilities may affect the ability of staff with certain disabilities to undertake specific tasksor work nights and/or shifts . The actual impact of these disabilities on individuals must beproperly understood and managed .

Mitigation

Met Detention will develop a strategy to :

1) Increase the confidence of disabled staff to declare their conditions and ,

2) Increase awareness of and competency in managing Disability amongst its leaders .

When disabilities have been identified a 'tailored adjustments agreement' must be developedleading to a DD roDriate reasonable adjustments .

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Potential External Impacts

There is no such legal requirement for LA to provide AA support for vulnerable adults in the sameway as for juveniles . This is currently dealt with on an individual borough basis leading toinconsistent service delive ry .

Many detainees are vulnerable when affected by Mental Health issues , Learning Difficulties ,Alcohol and/or substance misuse , and social issues such as homelessness . This can lead to self-harm , deaths in or following detention/contact and suicide following police custody .

The taking of people who need immediate access to critical Mental Health support to custodyfacilities using S136 puts them into an environment that can make their issues worsen .

New build or recently refurbished custody suites are largely ac cessible to users with physicaldisabilities . However, some older custody suites (particularly those in poli ce stations built in the lastcentu ry e . g . Kentish Town & Notting Hill ,) are not suitable for users in wheelchairs - even on ashort term basis .

Again , the facilities within new build or recently refurbished suites are largely accessible to userswith physical disabilities . Facilities include :

• Doorways are wide enough to accommodate a standard size wheelchair ,• Low level assistance call buttons and low level wash basins ,

• Cells with clear fronted doors for vulnerable / claustrophobic detainees ,• Disabled showers & toilets , and• Discrete Charge Rooms that incorporate low level counters to allow privacy for sensitiv e

matters that are accessible to wheelchair detainees .

However, there are areas within new builds that need further development to support wheelchairusers including :

• Interview and Consultation rooms need tables that have a fixed underside height with a gapthat is sufficient to allow a wheelchair user , detainee or legal representative , to sit at thetable in the same manner as an able bodied person and ,

• Photographic rooms need to be redesigned to allow wheelchair users access to thecamera .

Mitigation

Met Detention is reviewing the provision of AA support for vulnerable adults to support LAs providethis service to a more consistent standard .

The MPS has already undertaken significant work in safeguarding detainees through initiativesdesigned to improve both initial and pre-release risk assessments and , to ensure the safe hand-over of detainees to relatives , carers or professionals in-line with recommendation 18 of LordAdebowale 's report . It is introducing Liaison and Diversion Mental Health nurses in all suites toassist in-custody care and the effective pathway of vulnerable detainees to Mental Health andLearning Difficulties support in-line with recommendation 17 of Lord Adebowale 's report . MetDetention will build on this developing specific safeguarding guidance and integrated healt h

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pathways to support a wide range of vulnerabilities .

It will develop a culture whereby assumptions are not made about challenging or unusualbehaviour . Rather these will be seen as triggers to consider vulnerability . Staff will be trained in theuse of the Vulnerability Assessment Framework (reflecting the National Decision Making model , )and the Newcastle Risk Assessment tool introduced in-line with recommendation 19 of LordAdebowale 's report . A dedicated Suicide Prevention & Intervention Strategy officer has beenemployed to develop an in custody suicide reduction strategy .

Inspections carried out by the Met Detention Professionalism Unit will focus on risk andvulnerability reviewing :

• Pre-release Risk Assessments

• Strip Searches

• Compliance with 4Rs

• Supervision and enforcement of standard s

• Management of alcohol dependant detainees and those under the influenc e

• Vulnerable detainees

The MPS and partners are working towards S136 detentions in custody being a never event . It isalready a never event for children . The number of adults detained is ve ry low compared to theoverall number of detainees and is falling . Between Janua ry 2013 and December 2013 87 adultswere detained in MPS custody suites via S136 . Between Janua ry 2014 and July 2014 16 adultswere thus detained .

Met Detention has reviewed the accessibility of each suite to disabled users . Any necessa ryimprovements will be undertaken in conjunction with Property Services Department . The MetDetention implementation project team will :

• Map custody resources to the disability provisions of the Equality Act and provideinformation to Met CC so that they can ensure that wheelchair users who have beenarrested are only taken to custody suites than are Equality Act 2010 - Disability compliantand ,

• Ensure that future estate development complies with the Equality Act 2010 .

Met Detention will review the accessibility of all facilities w ith in suites for disabled users .

Sex

Potential Workforce Impacts

The impact of gender specific conditions e . g . menopausal changes affecting women has not beenfully evaluated .

Met Detention acknowledges the need to develop strategy to increase the number of female staff .

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Carer responsibilities are predominantly connected to children . Although male staff undertake thecarer role these are normally disproportionally performed by female staff . This is particularly thecase for CNP who are mainly female with a high % having carering responsibilities .


Not fully evaluate d

Gender Reassignment


No data is gathered regarding whether a member of staff is transgender.

Gender reassignment is a very sensitive issue that has parallels to disability - particular staff withmenta l hea lth conditions or learning difficu lties .

Consideration needs to be given to what functions reassigning staff can undertake e .g. searchingduring reassignment .

Mitigation

Met Detention wi ll develop a strategy to :

1) Increase the confidence of transgender and reassigning staff to dec l are, and

2) Increase awareness of and competency in managing transgender and reassigning amongst itsl eaders.


Generally custody officers and DDOs spoken to by DCFD had a very poor know ledge oftransgender and reassignment matters .

This may affect the abi l ity of Met Detention staff to dea l with transgender and reassigningdetainees appropriately .

Mitigation

On each visit the DCFD Inspection Team supp l ied transgender too l kits specifica lly aimed atcustody officers and DDOs/searching officers .

These too lkits are avai l ab le on the DCFD website . Met Detention wi ll ensure that they areincorporated within their own too l kits .

Transgender and reassigning awareness training will be incorporated within Met Detention training .

Marriage and Civil Partnership (employment only )

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No impacts identified .

Pregnancy and Maternity


Appropriate risk assessments wi ll need to be undertaken for staff who are pregnant

Mitigation

Met Detention wi ll comply with MPS guidance on the management of staff that are pregnant or ar eon maternity leave .

Safety contro l measures inc luding flexib le working, no contact with detainees and change of ro l ewi ll be imp l emented .


Issues regarding the provision of chi l dcare if a person with chi ldren is detained in custody .

Mitigation

Met Detention will review its toolkits to ensure that they provide appropriate guidance to suppor tdetainees that are pregnant or, were arrested with chi ldren and/or who have caring responsibi l itiesfor a chi l d e l sewhere .

Race


Not fu lly eva luated a lthough the disproportionate ly low numbers of BME members of staff withi nMet Detention has been acknow l edged.


The Se lf Defined Ethnicity of detainees shows distinct variations across London boroughs .

Current MPS custody systems do not a llow for the monitoring of Race, this is being consideredduring the discussions around the rep lacement system .

Mitigation

MPS custody suites a lready have protoco ls in p lace to ensure that peop le of different ethnicitie scan be appropriately cared for . Met Detention will review these prior to go-live .

ACI wi ll take on the responsibi l ity for consu ltation with l oca l communities regarding custodyservices and for ensuring that their diverse communities receive the appropriate service .

Religion and Belief

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Potential Workforce Impacts Allowing staff working patterns so that they may observe religiousevents , or fulfil daily obligations regarding their faith/ belief may affect operational delivery .

Mitigation

Although meeting operational demand buy having the correct number of staff on-duty takesprecedence, there is a large body of guidance available as to how reasonable adjustments can bemade to support the religious and/or faith/belief needs of staff .


DCFD found that generally good selections of articles concerned with religious observan ce werefound in the majority of the custody suites that they visited . Detainees were always allowed to car ryout ritual cleansing before prayer and were often permi tted to pray outside of their cells .

Two areas identified for improvement were :

1) No fixed/prominent signs indicating the direction of Mecca , and

2 ) Arabic versions of the Qur 'an weren 't stored or handled correctly

Mitigation

As is current practice , consideration will be given to ensuring that provision is made for dieta ryvariation and for religious observance in line with existing guidance for detainees in the MetDetention tool kit .

Wherever possible , Met Detention staff will take religious and faith/belief considerations whenundertaking a Pre-Release Risk Assessment . . For example not allowing an Orthodox Jewsufficient time to travel home before the Sabbath comes in would mean that person was strandedand unable to travel without breaking the rules of their faith . s?

Met Detention will deliver the following :

• A consistent method will be implemented across all Met Detention suites to indicate thedirection of Mecca . A Qibla will be stencilled on the ceiling of all cells and/or the cellcorridor,

• Localised responses will be developed with the Beth Din (Jewish Court) to support the release ofOrthodox Jews - taking into account future estate developments ,

• All Qur'an 's in Arabic will be replaced by a dual English /Arabic language version negatingthe need for special handling & storage conditions .

• If the custody kitchen area has more than one microwave then one should be set aside toreheat halal , vegetarian & kosher meal s

• Partnership agreements in place with a local Rabbi for kosher food to be brought in as andwhen required .

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• Clearly communicating to detainees that prayer mats and religious material are available o nrequest .

• A separate fridge to be used to store Kosher food away from non Kosher food . The need fo rthis will decrease as Met Detention moves towards ambient meals that will not require fridg estorage ,

• Met Detention will work with Staff Associations to arrange appropriate training events an densure that its toolkit offers sufficient guidance .

Sexual Orientatio n


Information on the sexual orientation of our workforce is available through the MetHR confidentia lscreen however , disclosure rates are low .

Mitigation

Met Detention will develop a strategy to :

1) Increase the confidence of staff of all sexual orientations to declare , and

2) Increase awareness of and competency in managing sexual orientation issues amongst it sleaders .


Not fully evaluate d

7 . Monitoring - see step 7 of the guidance

a) How will the implementation of the proposal be monitored and by whom ?Each ACI will be responsible for identifying and addressing operational issues regarding protecte dcharacteristics on their area .

The Met Detention Diversity lead will establish a working group to look at protected characteristics ,information gathering and training across the OCU .

Diversity will be a standing agenda item for the Met Detention SLT meeting allowing the OCUCommander to monitor issues brought to the meeting by the ACI and Diversity lead .

b) How will the results of monitoring be used to develop this proposal and its practices ?

The Met Detention Diversity Lead will use the monitoring process to review progress in developingproposals .

c) What is the timetable for monitoring , with dates?

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The Met Detention Diversity lead will update and re-publish the EIA on a 6 month basis .

8 . Public Availability of reports / result - see step 8 of guidanceWhat are the arrangements of publishing, where and by whom ?

Full EIA will be published externally on the Met Detention web pages .

MP 63/11

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